1. Sanctions Risk Policies
The Sanctions Risk Policies was first drafted on 29 March 2021.
The following policies applies to all staff, volunteers, it’s associates, partners, consultants, contractors and anyone else who engages with The Gaza Fund in any capacity, at any point in time.
SANCTIONS RISK STATEMENT:
The Gaza Fund is committed to complying with sanctions authorities and regulations in all jurisdictions through which it transacts. It is therefore our policy to undertake a zero-tolerance approach to transactions where a sanctions risk is identified.
OVERVIEW:
Sanctions, arms embargoes, travel bans, asset freezes, reduced diplomatic links, reductions/cessations of military relationships, suspension from international organisations, withdrawal of aid, trade embargoes, and other restrictions designated by:
- US Department of the Treasury’s Office of Foreign Assets Control (OFAC);
- Specially Designated Nationals and Blocked Persons (SDN) List;
- UK HM Treasury’s Office of Financial Sanctions Implementation (OFSI); &
- UN Restrictive Measures.
COMPLIANCE:
The priority at The Gaza Fund is to ensure none of our activities (including the receipt and disbursement of monetary donations) benefit individual(s) or parties who are being targeted for sanctions, unless an exemption, license, or other authorisation exists that allows for any transaction with that individual(s) or parties to occur. The screening should include all:
- Paid or unpaid staff and volunteers;
- Partner organisations;
- All suppliers and contractors in Gaza;
- All banks, FX providers and financial institutions and couriers involved in the bank transfer;
- All donors, large or small;
- All individuals/beneficiaries who receive cash donation as part of our Zakah programme.
SYSTEMS & PROCEDURES:
The Gaza Fund is committed to developing and strengthening systems, processes, procedures and controls to ensure that sanctions risks are readily identified and mitigated. For all staff and volunteers, as well as suppliers and contractors, this includes:
- Developing a screening and risk rating system;
- Encouraging a proper understanding of sanctions compliance;
- Developing a transparent system to escalate identified sanctions risks;
- Incorporating sanctions compliance with The Gaza Fund’ anti-money laundering and anti-terrorism policies and procedures to streamline compliance across the organisation; &
- Regularly reviewing implementation of current policies and procedures to monitor their effectiveness.
2. Money Laundering & Terrorist Financing Policies
The Anti-Money Laundering & Anti Terrorist Financing Policies was first drafted on 29 March 2021.
The following policies applies to all staff, volunteers, it’s associates, partners, consultants, contractors and anyone else who engages with The Gaza Fund in any capacity, at any point in time.
OVERVIEW:
Broadly, money laundering is the process of concealing the illegal origin of proceeds derived from crime. Terrorist financing is the provision, collection or receipt of funds intending or knowing that those funds will be used to support or carry out an act of terrorism. While the money laundering and terrorist financing risk in the NGO sector is low, some charities, particularly those operating in crisis-hit regions, may be exposed to greater risks.
CONSEQUENCE:
The impact of even one proven case will corrode public confidence in the affected charity and
the entire sector. It could also lead to charities experiencing transaction delays or denials or account closures by their banks due to concerns around money laundering and terrorist financing risks.
RESPONSIBILITY:
The Gaza Fund is committed to putting in place systems and processes to ensure that the charity is not used to launder money or finance terrorist activities, based on good practices.
To minimise our risk profile, we need to:
- maintain proper financial records of all donors as well as receipts of all expenses with a proper audit trails of decisions made.
- put in place appropriate internal financial controls to ensure that all funds are fully accounted for and are spent in a manner that is consistent with the charity’s purpose;
- take reasonable steps to ensure that the charity knows who its beneficiaries are, at least in broad terms, carry out appropriate checks in high risk situations and consistently apply clear beneficiary selection criteria.
- familiarise ourselves with the background and affiliations of our trustees, employees, fund-raisers, volunteers and other persons working on your behalf as well as of other persons with whom we work with closely;
- take reasonable steps to verify that our beneficiaries, donors and associates are bona fide and are not designated terrorists or subject to financial sanctions
- conduct financial transactions within mainstream financial channels such as bank accounts as far as is reasonably possible
- ensure The Gaza Fund is not infiltrated by banned groups (or banned individuals) and used to transfer proceeds of, and funds diverted to criminal activity;
- ensure not a single cent is raised for a terrorist cause or proceeds received by recipients that is later misused for terrorist purposes.
For details, visit https://thegazafund.com/our-expenses/
3. Related-Party Transactions Policy
The Related-Party Transactions Policy was first drafted on 29 March 2021.
This policy with respect to material Related Party Transactions at The Gaza Fund is intended to ensure that related party transactions (“RPTs”) are conducted in a manner that will protect The Gaza Fund and all its stakeholders from conflict of interest which may arise from such transactions, that the RPTs are entered into at, arms-length or at terms at least comparable to those available to unrelated third parties, and that these transactions shall be disclosed, reviewed, and approved in accordance with this Policy and consistent with the principles of transparency and fairness.
4. Anti-Bribery Policies
The Anti-Bribery Policy was first drafted on 29 March 2021.
The following policy applies to all staff, volunteers, it’s associates, partners, consultants, contractors and anyone else who engages with The Gaza Fund in any capacity, at any point in time.
The Gaza Fund attaches the utmost importance to this policy and will apply a zero-tolerance approach to acts of bribery and corruption by anyone i.e., employees, volunteers, consultants, service suppliers or business partners working on our behalf.
RESPONSIBILITY:
- Every single individual associated with The Gaza Fund is expected to declare any conflicts of interest prior to volunteering to work or help out at The Gaza Fund.
- Every individual associated with The Gaza Fund is also expected to safeguard and uphold The Gaza Fund’s core values by operating in an ethical and lawful manner at all times.
- Individuals are responsible for not giving or receiving bribes and challenging instances where bribery may occur by reporting all bribery that they are aware of, to wutokbong@gmail.com
CONSEQUENCE: Any member of staff found to have accepted or attempted bribery or made facilitation payments will be subject to disciplinary action, including dismissal.
DEFINITION: Bribery is the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisation’s activities.
EXAMPLES: Bribes can take on many different shapes and forms but typically they involve corrupt intent. There will usually be a ‘quid pro quo‘ – both parties will benefit. Examples of bribery may include:
(1) A potential supplier offering money or a gift in order to influence a tendering process; or
(2) Facilitation payments which induce officials to perform routine functions they are otherwise obligated to perform.
RECORD-KEEPING: Many serious global bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. The Gaza Fund maintains accurate records and financial reporting through its website, updated regularly. For details, visit https://thegazafund.com/our-expenses/
5. Use of Images Policy
The Use of Images Policy was first drafted on 29 March 2021.
We will try our best not to source, commission, purchase from stock image libraries or publish photographs that endanger and exploit vulnerable Palestinians, including women, girls and children.
While a picture says a thousand words, every effort will be made not to singularly use images to bolster fundraising. All images will also need to have accompanying text justifying the fund raising.
The key is to convey the urgent need for fundraising in an ethical way by meeting adequate standards in terms of dignified representation of people living in the Occupied Palestinian Territories and in Gaza.
6. Conflict of Interest Policy
The Conflict of Interest Policy was first drafted on 29 March 2021.
The basic principle to be observed is that no current or former officer(s), director(s), trustee(s), key employee(s) or volunteer(s) should not use their position to profit or gain some benefit or advantage for themselves or their related interests. They should avoid situations that may compromise their impartiality. If an actual or potential conflict of interest may arise on the part of any current or former officer(s), director(s), trustee(s), key employee(s) or volunteer(s), they should fully and immediately disclose it and should not participate in the decision-making process.
A conflict of interest shall be considered material if the current or former officer, director, trustee, key employee or volunteer’s personal or business interest is antagonistic to that of The Gaza Fund, or stands to acquire or gain financial advantage at the expense of The Gaza Fund.
Each current or former officer, director, trustee, key employee or volunteer has a responsibility to The Gaza Fund to avoid situations where a conflict of interest might occur. Employees too, are expected to devote their full attention to the interests of The Gaza Fund. They are prohibited from engaging in any activity that interferes with the performance of their responsibilities to The Gaza Fund or is otherwise in conflict with or prejudicial to The Gaza Fund. Full-time employees are prohibited from accepting simultaneous employment with another charity or NGO, or with a supplier and/or customer.
Willful withholding of information regarding a prohibited relationship may be subject to corrective action.
7. Personal Data Protection Policy
The Personal Data Protection Policy was first drafted on 29 March 2021.
GDPR Compliance: Personal data is an Amanah. For accounting reasons, we keep copies of all bank receipts and proof of payments however as part of our privacy policy, do not publicise names of individual donors on our website, to comply with the General Data Protection Regulation (GDPR). To find out more, email wutokbong@gmail.com
Site Visit Data: This website records your visits and logs the following information for statistical purposes: the type of browser you use; the date and time you access the site; the pages you have accessed and the previous Internet address from which you linked directly to the site. Unless you have donated before via WhatsApp, we do not collect any personally identifying information about you, and in any case, will not disclose any information to third parties. We fully support you using a nickname rather than your real one, or using an anonymous email address if you are more comfortable doing so.
Cookies: We do not store cookies or other persistent tracking identifiers on your device. We use a service that provides usage analytics for the website. It is configured to only collect anonymised statistics and not store persistent identifiers such as cookies. All data related to this is deleted from your device at the moment you close your browser window.
Data Security: Our internal data protection policy defines how we deal with data and by what information technology means our data can be processed and how the systems used comply with current security requirements. We have taken technical and operational precautions to minimise the amount of personal data we store and protect it from unauthorised access and misuse. Our security procedures are monitored regularly and updated.
Social Media: If you would like to follow us, but wish to remain anonymous, we’d encourage you to join our Telegram group, as it offers the best privacy.
8. Donor’ Soft Power Policy
The Donor Soft Power Policy was first drafted on 29 March 2021.
Donor’ soft power can be influential, leading to last-minute changes or a public statement from a person of influence. As a charity, The Gaza Fund is committed to building mechanisms to limit donors’ reach and influence within the organisation. On the one hand, we will build strong and trusting relationships with donors while also setting limits, spelling out conditions in gift agreements, on their power over programmatic, policy and personnel matters.
GUIDING POLICIES:
As conceived by Aid Watch Palestine (AWP), an independent grassroots Palestinian initiative in Gaza:
- [The Gaza Fund] will not pursue or accept funding that comes with pressure to take a particular political stance or to increase or decrease scrutiny of [any aid organisations] or that restricts the kind of aid monitoring The Gaza Fund can do.
- If [The Gaza Fund] experiences coercive pressure from a donor, and if the conflict cannot be resolved quickly, [The Gaza Fund] will initiate efforts to return the funds, and the decision and implementation of the decision will be documented in public reports.
- Funding will not be pursued or accepted from parties that are widely considered by the Palestinian community as undermining Palestinian rights.
- Funding will not be pursued or accepted from parties that require purchasing materials or services from Israel or a donor country.
- All funding for [The Gaza Fund] must be legal, transparent, and professional. We will not accept anonymous contributions in excess of [the equivalent of] US$1,000, or more.
- We do not knowingly accept contributions from anyone who stands to benefit financially from our work.
- [The Gaza Fund] will not accept any non-cash gifts that are counter to or outside the scope of its MISSION and OBJECTIVE, unless the item would produce needed revenue.
- In order to maintain stability and independence, [The Gaza Fund] strives to maintain a diversity of funding sources and to avoid being more than 25% dependent on any one donor.
- All grants or contributions will be reviewed on a case-by-case basis and when necessary legal advice will be obtained.
- [The Gaza Fund] will carry out regular internal audits and annual external audits, once formally registered as a charity.
- All funding reports will be presented within three months or within twelve calendar months at the most.
9. Whistle Blowing & Open Door Policies:
The Whistle Blowing & Open Door Policies was first drafted on 29 March 2021.
The open door policy is a voluntary process that allows any current or former officer(s), director(s), trustee(s), key employee(s) or volunteer(s) at The Gaza Fund and/or third-party supplier(s) or vendor(s) to directly communicate with The Gaza Fund, without fear of retaliation.
APPROPRIATE ACTION: The Gaza Fund will investigate any actual or potential violations reported to us. If after such investigation, we are led to believe that a violation has occurred, The Gaza Fund will consider taking appropriate action.
To send a secure & anonymous note at anytime, please email: wutokbong@gmail.com